Fair Practice Code

Bee Secure Home Finance Pvt. Ltd. (hereinafter referred to as “the Company” or “we”) has framed and adopted this voluntary code, which sets the fair practice standards while dealing with individual customers. The Code has been prepared based on the Guidelines issued by National Housing Bank on Fair Practices Code from time to time.

Objectives of the Fair Practices Code

The Code has been adopted:

a) To promote good and fair practices by setting minimum standards in dealing with customers;

b) To increase transparency so that the customers can have better understanding of what they can reasonably expect of the services;

c) To encourage market forces through competition, to achieve higher operating standards;

d) To promote a fair and cordial relationship between customers and the Company;

e) To foster confidence in housing finance system.

Application of the Code

This Code applies to all the products and services offered by the Company whether over the phone, across the counter, on the internet or by any other means. It will apply to all the employees and representatives of the Company.

COMMITMENT OF THE COMPANY

2.1 The Company will act fairly and reasonably in all dealings with customers, by ensuring that:

a) It meets the commitments and standards in this Code for the products and services they offer and in the procedures and practices their staff follows.

b) Its products and services meet relevant laws and regulations in letter and spirit.

c) Its dealings with customers rest on ethical principles of integrity and transparency.

2.2 The Company will transparently disclose to the borrower:

a) Fees / charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned / disbursed,

b) Pre-payment options and charges, if any;

c) Penalty for delayed repayment if any;

d) Conversion charges for switching loan from fixed to floating rates or vice-versa;

e) Information interest reset clause, if any, and any other matter which affects the interest of the borrower;

Thus, the Company disclose ‘all in cost’ inclusive of all charges involved in processing / sanction of loan application in a transparent manner.

2.3 Non-Discrimination Policy

The Company will not discriminate between its customers based on gender, physical ability, race or religion. The Company will also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from instituting or participating in schemes framed for different sections of the society.

DISCLOSURES, ADVERTISING, MARKETING AND SALES

3.1 The Company shall:

a) Ensure that all advertising & promotional material is clear and not misleading.

b) In any advertisement in any media or promotional literature that draws attention to a service or product that includes a reference to an interest rate, the Company will also indicate whether other fees and charges will apply and ensure that full details of the relevant terms and conditions would be made available on request.

c) Provide information on Interest Rates, Common Fees and Charges through any one or more of the following media:

i) Putting up notices at all our branches;

ii) Through telephone or helplines;

iii) On the Company's Website, as and when launched;

iv) Through designated staff / helpdesk.

d) If the Company avails services of third parties for providing support services, it shall require that such third parties handle customer's personal information (if any available to such third parties) with the same degree of confidentiality and security as it would.

e) The Company, from time to time, communicate to customer various features of the products availed by them. Information about its other products or promotional offers in respect of products / services, may be conveyed to the customers only if he/ she has given his/ her consent to receive such information/ service either through the application form/ loan agreement or by mail or by registering for the same on the website or on the Customer Service Number.

f) Prescribe a Code of Conduct for Direct Selling Agents (DSAs), whose services are availed to market products of the Company. Such Code of Conduct, amongst other matters, require them to identify themselves when they approach the customer for selling the Company’s products.

g) In the event of receipt of any complaint from the customer that the Company’s representative/ courier or DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.

LOANS

4.1 Applications for loans and their processing

a) At the time of sourcing a loan proposal, the Company shall provide information about the applicable interest rates, fees/ charges etc. and any other important information which affects the interest of a borrower, so that a meaningful comparison and informed decision can be taken by the borrower.

b) The Company will issue an acknowledgement receipt for all loan applications. Loan applications shall be disposed of within 15 days or such extended time as may be mutually agreed between the borrower and the Company from the date of receipt of the application form complete in all respects.

4.2 Loan appraisal and terms/conditions

a) Normally all details/ documents required for processing the loan application will be collected by the Company at the time of application. If any additional detail/ document is required, the Company will contact the customer again at the earliest possible instance.

b) The customer would be informed by means of a written sanction letter of the amount of loan sanctioned or otherwise; all important terms and conditions including Annualized Rate of Interest, method of application of rate of interest, EMI structure, prepayment charges etc. The Company will keep the written acceptance of these terms and conditions by the borrower on its record.

c) The Company will furnish a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement to every borrower at the time or after disbursement of loans.

4.3 Communication of rejection of Loan Application

If the Company is not in position to provide the loan to the customer, it shall communicate in writing the reason (s) for rejection.

4.4 Disbursement of loans including changes in terms and conditions

a) The Company will disburse the loans in accordance with the disbursement request made by the customer or the disbursement conditions mentioned in the Loan Agreement/ Sanction Letter;

b) The Company will give notice to the borrower of any change in the terms and conditions including changes in terms & conditions relating to disbursement schedule, interest rates, service charges, prepayment charges, other applicable fee/ charges etc. The Company will also ensure that revisions in rate of interest and charges are effected only after notification to the customer. A suitable condition in this regard will be incorporated in the loan agreement.

c) If such change in terms & conditions is to the disadvantage of the customer, he/she may within 60 days and without notice close his/ her account or switch the loan account without having to pay any extra charges or interest.

d) Decision to recall / accelerate payment or performance under the agreement or seeking additional securities, shall be in consonance with the loan agreement.

e) The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled /paid.

4.5 Guarantors

When a person intends to be Guarantor for a loan, he / she shall be informed about:.

a) His / her liability as guarantor;

b) The amount of liability he/ she will be committing himself/ herself to the Company;

c) Circumstances in which we will call on him/ her to pay up his/ her liability;

d) Whether his / her liabilities as a guarantor are limited to a specific quantum or are they unlimited;

e) Time and circumstances in which his/ her liabilities as a guarantor will be discharged as also the manner in which the Company will notify him / her about the same;

f) The Company will keep him/ her informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor, if it becomes aware of it; and

g) In case the guarantor refuses to comply with the demand made by the creditor/ lender, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter as per the extant regulatory prescriptions.

PRIVACY AND CONFIDENTIALITY

5.1 Credit Reference Agencies/ Credit Information Companies

a) The Company may share details of the loan and repayment track record of its borrowers to the Credit Information Companies as per the regulatory directions/ guidelines or the Company’s internal policies.

b) The Company may share information with the Credit Information Companies about the personal debts the customer owes it if:

i) The customer has fallen behind his/her payments

ii) The amount owed is not in dispute

iii) The customer has not made proposal following our formal demand for repayment of dues.

c) At the same time, the Company representatives will explain to the customers the role of the CICs and the effect the information they provide can have on customer’s ability to get credit.

d) The Company will give information about the customer’s account to the CICs if the customer has given his/her permission to do so OR the statutory/ regulatory requirements prescribe so.

e) The Company will provide relevant information given to the CICs if demanded by the customer.

5.2 Sharing of information

a) The Company may provide such information to its group/associate entities or companies for which it has obtained consent/ permission from its customer under loan application/ sanction letter/ loan agreement.

b) The Company will treat the personal information of customer even when the customer is no longer a customer as private and confidential. We will not reveal the data or information of customer to anyone except as provided above and in the following exceptional cases:

i) Required by law;

ii) Duty towards public to reveal information;

iii) The Company’s interest requires giving information;

iv) The Company has consent/ permission from the customers;

v) The Company’s representatives will inform the customer about his rights/ liabilities under the Laws of India for accessing the personal records that the Company holds about him/her;

vi) The Company will not use customer’s personal information for marketing purposes unless the customer specifically authorizes us to do so.

COLLECTION OF DUES

6.1 When the loans are given, the Company’s representatives will explain to the customer the repayment process by mentioning amount, tenure and periodicity of repayment in the welcome letter. However, if the customer does not adhere to repayment schedule, a defined process in accordance with the laws of the land shall be followed for recovery of dues. The process will involve reminding the customer by sending him/ her notice or by making personal visits and / or repossession of security, if any.

6.2 The Company’s collection policy/ process shall be built on courtesy, fair treatment and persuasion. We believe in fostering customer confidence and long-term relationship. The Company’s staff or any person authorized by it for collection of dues or/ and security repossession shall identify himself / herself and display the authority letter issued by the Company and upon request, display his / her identity card issued by the Company or under authority of the Company.

6.3 The Company’s employees or any person authorized by it to represent it for collection and/ or security repossession shall follow the guidelines set out below:

a) Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation.

b) Identity and authority to represent the Company shall be made known to the customer at the first instance.

c) Customer's privacy would be respected.

d) Interaction with the customer shall be in a civil manner.

e) The Company’s representatives shall contact the customers between 0700 hrs and 1900 hrs, unless the special circumstances of the customer's business or occupation require otherwise.

f) The Company will endeavor to consider the customer's request to avoid calls at a particular time or at a particular place and such requests shall be honoured, as far as possible.

g) A tracker with time and number of calls and gist of conversation would be maintained.

h) All assistance would be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.

i) During visits to customer's place for dues collection, decency and decorum shall be maintained.

j) Inappropriate occasions such as bereavement in the family or such other calamitous occasions would be avoided for making calls / visits to collect dues.

GRIEVANCE REDRESSAL MECHANISM

Any customer having a grievance/ complaint/ feedback with respect to the product and services offered by Bee Secure Home Finance Pvt. Ltd. (hereinafter referred to as ‘the Company’) may write to the Company’s Customer Service Department through any of the following channels:

Call at 18605002192
Email - care@incred.com
You may write a letter at the address- Bee Secure Home Finance Private Limited 1502 B Wing, The Capital Bandra Kurla Complex Bandra (East) Mumbai 400051
Website - www.incred.com

How a complaint should be made:

Customers are requested to necessarily provide necessary loan details i.e. Loan Account Number, Details of Feedback/ Suggestion/ Complaint and valid Contact Information including phone no. & e-mail ID while lodging communicating with the Company.

When to expect a reply

The Company shall endeavor to address/respond to all queries/grievances within reasonable time and keep the customer in informed about the status of their complaints. Each customer query/ complaint being unique in nature, may take up to 4 weeks for complete resolution after investigation.

Whom to approach for redressal

Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timelines, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:

Name: Magesh Iyer
E-mail ID.: beesecure.grievance@incred.com
Telephone no.: 022-42117799
Address: Bee Secure Home Finance Private Limited 1502 B Wing, The Capital Bandra Kurla Complex Bandra (East) Mumbai 400051

Escalation to National Housing Bank

In case the Customer does not receive any response from the Company within 4 weeks or is dissatisfied with the response received, the customer may approach the Complaint Redressal Cell of National Housing Bank by lodging its complaint in online mode at the link https://grids.nhbonline.org.in OR in offline/ physical mode by post to the following address:

 National Housing Bank, Department of Regulation and Supervision (Complaint Redressal Cell), 4th Floor, Core- 5A, India Habitat Centre, Lodhi Road, New Delhi-110003

 Such complaint may also be e-mailed at crcell@nhb.org.in

GENERAL

8.1 If the Company considers it necessary, it will verify the details mentioned by the customer in the loan application by contacting the customer at his/ her residence and/or business addressees through agencies appointed for the purpose.

8.2 The customer is expected to co-operate if the Company needs to investigate a transaction on the customer's account and with the police/ other investigative agencies, if the Company needs to involve them.

8.3 The customer will be responsible for all losses if such customer acts fraudulently or without reasonable care.

8.4 The Company will give customers information about our products and services in English normally. However, if requested by the customer, such information shall be provided in Hindi or any other appropriate local language.

8.5 The Company will process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.

INTEREST CHARGES

Home Loan

Min Rate = 10.50% and Max Rate = 16%

LAP

Min Rate = 12.50% and Max Rate = 16.50%